Commissioner v. Smith, 324 U.S. 177 (1945)

U.S. Supreme Court

Commissioner v. Smith, 324 U.S. 177 (1945)

Commissioner of Internal Revenue v. Smith

No. 371

Argued January 30, 31, 1945

Decided February 26, 1945

324 U.S. 177

Syllabus

An employer gave to its employee as compensation for his services an option to purchase shares of stock at a price not less than the then value of the stock. The option had no value at that time, and the compensation contemplated by the parties was the transfer to the employee of the shares of stock after their value had increased to more than the option price.

Held, under § 22(a) of the Revenue Act of 1938 and of the Internal Revenue Code, the employee received "compensation for personal service," and hence taxable income in each year in which stock was acquired, through effective exercise of the option in that year, in the amount of the difference between the pt.ion price and the then market value of the stock. P. 324 U. S. 181.

142 F.2d 818, reversed.

Certiorari, 323 U.S. 696, to review the reversal of a decision of the Tax Court which sustained the Commissioner's determination of a deficiency in income tax.

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